Data protection information SEW-EURODRIVE

Thank you very much for your interest in the websites of SEW-EURODRIVE Polska Sp. z o.o., our mobile applications and our products and activities.

The protection of the privacy of your personal data is an important element issue that we take into account in our business processes. We therefore process your personal data taking into account the relevant data protection regulations, in particular the guidelines of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (‘GDPR’).

Below we provide you with information regarding the processing of your personal data by SEW-EURODRIVE Polska Sp. z o.o. Depending on the ways and purposes for which we process your personal data, only selected information shall be applicable to you.

The Controller of your personal data is SEW-EURODRIVE Polska sp. z o.o. with its registered office in Łódź, ul. Techniczna 5 92-518 Łódź, entered in the Register of Entrepreneurs kept by the District Court for Łódź-Śródmieście in Łódź, 20th Commercial Division of the National Court Register under National Court Register number: 0000079236, NIP (Tax ID): 7261678845, REGON (Business ID): 471388462 (hereinafter referred to as ‘SEW-EURODRIVE’ or ‘Controller’).

You can contact us in relation to data protection and the exercise of your rights in the following ways:

• contact form on the website at: www.sew-eurodrive.pl
• contact phone: +48 42 270 90 00
• sending a letter to our address: SEW-EURODRIVE Polska Sp. z o.o., ul. Techniczna 5, 92-518 Łódź

The Controller has appointed a Data Protection Officer. This is Ms. Katarzyna Lamczyk. You can contact her regarding data protection issues and the exercise of your rights by email: rodo@sew-eurodrive.pl or by sending a letter to the mailing address indicated above.

I. What is personal data

II. Information for users of our websites and mobile applications, including a ‘cookie policy’

III. Purposes and means of processing data of customers and users of the SEW-EURODRIVE websites

IV. Data protection information for suppliers and subcontractors

V. Purposes and uses of employee candidate data at SEW-EURODRIVE

VI. Data protection information for visitors to SEW-EURODRIVE

VII. Data protection information in the context of data processing in the context of trade fairs or other events

VIII. Data protection information regarding the taking and publication of photos, sound and video recordings as well as press releases and advertising texts

IX. Data protection information in the context of using Microsoft Teams as a collaboration platform

X. Data protection information in the context of video surveillance

XI. Data subjects' rights

I. Definition of personal data

Personal data are any information relating to an identified or identifiable natural person. This includes, for example, your first name, last name, contact details including telephone number or e-mail address, as well as any information about you that we process in connection with the relationship between us.

When you use our website, online forms or registration-based services (e.g. OnlineSupport), we may process personal data such as your first name and last name, contact details (in particular e-mail address and telephone number), company-related data (e.g. company name, tax identification number, position), as well as technical data related to the use of the service. Technical data are generally collected through the use of log files and cookies. These data may also be used for purposes related to the security of services requiring registration, including the prevention of abuse and ensuring the integrity and availability of systems.

In relation to job applications submitted via the website, personal data includes information provided by the candidate in connection with participation in the recruitment process, in particular first name and last name, contact details, information provided in application documents (e.g. CV, cover letter), education and professional experience, as well as other information voluntarily provided during the recruitment process.

II. Information for users of our websites and mobile applications, including a ‘cookie policy’

Below you can find information about how we process your personal data in connection with your visit to our website and other forms of online contact with us, including what types of personal data we process, for what purposes and to what extent.

II. 1. Processing of our website users' data

When you access our website or use SEW-EURODRIVE online services, including services that require user registration, general information is automatically collected. This information (server logs) includes type of Internet browser, operating system used, domain name of your Internet service provider, etc. Where the IP address is processed solely for technical and security purposes, the legal basis for processing is the legitimate interest of the controller. The collection of this information is technically necessary and required for the proper delivery of content and to ensure the continuous availability of the website and mobile applications. Where data processing is carried out using analytical or marketing cookies, the legal basis for processing is the user’s consent (Article 6(1)(a) GDPR). Personal data are stored for no longer than is necessary to achieve the stated purposes and are then anonymised or deleted in accordance with applicable retention periods, unless other legal grounds for processing apply, for example unless one of the following situations occurs:

• you send us an enquiry by email – in this case we shall process your personal data for the purpose of responding to your enquiry. The legal basis for the processing in this case is Article 6(1)(f) of the GDPR.
• you use the services offered on our websites ─ in this case we shall process your personal data to the extent that it is necessary for the performance of these services. The legal basis for the processing is Article 6(1)(b) of the GDPR.

If one of the situations described above occurs, in particular if you provide us with data in connection with entering into an agreement with us or registering on our website, please read the data protection information set out in section III.

Further processing of your data by us or other companies of the SEW-EURODRIVE Group or external service providers beyond the purposes indicated above takes place depending on the use you have chosen for your data, as set out below, or if you have given your consent.

II. 2. General enquiries and business correspondence via the online contact form

In addition to contacting us by telephone and e-mail, you can also use the online contact form to send us your (general) enquiries about us or our products and services. Using the contact form is one of the available means of contact and is not mandatory. We process the data that you have entered in the form on our servers in Bruchsal. The form includes required information which we need in order to process and respond to your inquiry, as well as voluntary information that you may provide at your own discretion. The data are as follows:

• E-mail address (required information)
• Postal code (required information)
• Subject of your inquiry (voluntary)
• Content of your message (voluntary)
• Academic title (voluntary)
• Customer number (voluntary)
• Name, surname (voluntary)
• Company name (voluntary)
• Street name, house number, town/city (voluntary)
• Country/region (voluntary)
• Telephone number (voluntary)
• Telephone extension (voluntary)
• Cell phone number (voluntary)
• Attachments that you upload via the form (voluntary)

Personal data are processed for the duration of the user’s consent, until such consent is withdrawn or. where processing is carried out on the basis of the controller’s legitimate interests until an effective objection is raised or the purpose of processing ceases to exist, unless further processing of the data is required under applicable provisions of law.

The legal basis for the processing of personal data provided via the contact form is Article 6(1)(a) of the GDPR, i.e. the user’s consent expressed by voluntarily completing and submitting the contact form as the selected means of contact with the controller.

Irrespective of the above consent, the processing of personal data in the course of handling enquiries and conducting ongoing correspondence is also based on Article 6(1)(f) of the GDPR, i.e. the controller’s legitimate interest consisting in responding to enquiries and conducting communication concerning the activities, products and services of SEW-EURODRIVE.

Where the content of the enquiry concerns the conclusion of a contract, the performance of a contract, or the taking of steps at the request of the data subject prior to entering into a contract, the legal basis for the processing of personal data is Article 6(1)(b) of the GDPR.

II. 3. General guidelines for security online and on external links

We take appropriate technical and organisational security precautions on our websites to protect personal data stored by us against access by third parties, loss or misuse, and to enable secure data processing and transfer.

At the same time, we encourage caution when using the Internet and e-mail, as despite the security measures applied, the risk of unauthorised access to data during transmission cannot be completely excluded. For this reason, we recommend you to take appropriate measures to protect your own data, in particular by using secure passwords and protecting your devices.

Our websites may contain links to websites operated by third-party providers. Once you access such websites, separate privacy policies and data processing rules applied by their administrators shall apply. SEW-EURODRIVE shall not be liable for the content published on such websites or for the processing of personal data by third parties.

II. 4. Online Support

On our website, you may register and create an individual customer account within our “Online Support” service, which provides access to online support, including consultations, the ability to place orders, track deliveries, order troubleshooting and other SEW-EURODRIVE functions and services. In such cases, the purpose, scope and legal basis for the processing of personal data may vary depending on the specific functionality of the service or the commissioned service. Where a customer account is created on the portal, the legal basis for the processing of your personal data is Article 6(1)(b) of the GDPR, i.e. processing necessary for the performance of a contract or for taking steps at the request of the user prior to entering into a contract.

In addition, we may process your personal data for purposes related to ensuring the proper operation, development and optimisation of the Online Support service, as well as improving user experience. In such cases, the legal basis for the processing may be the controller’s legitimate interest (Article 6(1)(f) of the GDPR) or the user’s consent (Article 6(1)(a) of the GDPR), depending on the nature of the given functionality or the tools used. You can find more information about the processing of personal data for these purposes in sections II and III.

II. 5. Advertising mailings

If you have given your prior consent (e.g. by means of a form), we shall send you information about our products and services by e-mail.

Notwithstanding the above, we may send you promotional and marketing information such as information about trade fairs, products and services by post to your postal address, based on the controller’s legitimate interest, unless you have objected to receiving such correspondence. For more on the use of your personal data for advertising purposes, please see section III.1.

You may revoke your consent to receive advertising mailings or object to the use of your data for advertising purposes sent to your postal address at any time. For the purpose of revocation, please contact us by telephone, e-mail or via the form.

II. 6. Mobile apps

We offer you access to our mobile applications available in the Apple App Store and Google Play Store. When you download these applications, certain user data are transmitted directly to the operator of the relevant app store, in particular user account identification data, information on the download of the application and billing data, in accordance with the rules applicable in the relevant store. The app store operator acts as an independent controller of personal data and processes user data in accordance with its own rules, over which SEW-EURODRIVE has no control. In order to review the scope of data processing by the store, we recommend reading the privacy policy of the store from which you intend to download our application.

When using mobile applications, we process your personal data solely to the extent necessary to install the application on your device, enable the use of its functionalities and ensure its proper functioning, stability and security.

Depending on the functionalities used and the device settings, it may be necessary to process technical data relating to the device or the application, such as information on the operating system, device model, application identifiers, e-mail address or telephone number, provided that such data are necessary for specific application functions. You may access specific data or device functions only after you have given prior consent in the application or operating system settings. The legal basis for the processing of personal data in connection with the use of mobile applications is Article 6(1)(b) of the GDPR, i.e. processing necessary for the performance of a contract or for taking steps at the request of the user prior to entering into a contract.

II. 7. Information on the use of technical means (‘Cookie Policy’)

Below are the cookies and tools used on our website:

Our website (and some of our applications) use technical aids that perform various functions, in particular what are known as cookies. Cookies are small text files stored on your device which are saved by your Internet browser. They serve to make our services more user-friendly, more efficient and more secure. We use both temporary (session) cookies, which are deleted when you close your browser (‘Session Cookies’), and persistent cookies.

When visiting our website (or using the app) and at any later point in time, you have the option of choosing whether or not to authorise the use of cookies or individual additional functions. You can make changes in your browser settings or via our Cookies Control Panel.If you choose to reject the use of cookies, you may not be able to make full use of our services.

In the context of the use of cookies, we distinguish between cookies that are absolutely essential (for the display and operation of the website) and cookies for other purposes, such as anonymous measurement of the number of visits (functional cookies) and marketing cookies (advertising purposes, display of relevant and personalised content). The various purposes of processing and the specific services used are outlined below, and the data processing involved is described.

a) Essential cookies

Essential cookies are used to ensure the proper functioning of the website and its basic functionalities, including the secure use of services requiring registration, such as Online Support. These are in particular session cookies, which allow us to recognise the user within a single browser session. If personal data (e.g. the IP address) are processed as part of essential cookies, such processing takes place in order to ensure the security, stability and proper functioning of the website. The legal basis for the processing of personal data as part of essential cookies is Article 6(1)(f) of the GDPR, i.e. the controller’s legitimate interest.

b) Voluntary cookies

With your consent, we use functional and marketing cookies. Functional (analytical) cookies make it possible to analyse how the website is used, including the creation of visit statistics and the improvement of its functioning. For this purpose, we may use analytical tools such as Microsoft Clarity or other similar statistical tools. Marketing cookies enable marketing activities, including the display of content tailored to the user’s interests and the measurement of the effectiveness of marketing campaigns. Functional and marketing cookies are used only after the user has given prior consent, which may be withdrawn at any time.

We use the following tracking functions:

etracker

This is a tool used to compile statistics on the use of our website. The provider of the tool is etracker GmbH with its registered office in Hamburg, Germany (www.etracker.com). If you give your prior consent, this tool may occasionally use functional cookies that allow us to statistically analyse the use of our website by visitors and to present marketing content. Data that may enable the identification of an individual, such as an IP address, registration identifiers or device identifiers, are then pseudonymised or anonymised as quickly as possible. We may also occasionally use the etracker tool in an option without the use of cookies. In such cases, we do not use information that allows the user to be clearly identified.

Personal data processed by etracker are stored in the European Union, in accordance with our guidelines, and are thus subject to European data protection laws and standards. etracker does not process data for its own purposes and has been independently assessed for compliance with EU data protection standards and certified with the ePrivacyseal data protection seal.

Data processing in etracker takes place on the basis of Article 6(1)(a) of the GDPR, i.e. your consent. You may withdraw your consent to the processing of data using the etracker tool at any time. For more information on data protection at etracker, please follow the link.

Statistics tool

We also use our own internally developed tool that enables us to conduct analyses on the use of our website and Online Support.

If you remain not logged in to our website, we will not identify you on the basis of the data and information provided. In such cases, we place cookies in the browser of your device (e.g. a computer) and assign a random session ID, solely for analytical and statistical purposes. The cookies will also contain the following information about your device:

• screen size
• screen resolution
• type of device
• operating system and version
• browser
• information as to whether cookies are activated in the browser
• geo data (continent, country, region, city)
• timestamp (date, time of login)
• ‘click data’ (individual applications accessed)
• search queries
• ‘abandoned shopping carts’ (product placed in the shopping cart but not ordered)
• bandwidth and Internet provider

We analyse the above information in order to assess whether and how non-logged-in users make use of our Online Support offer.

However, if you log in to Online Support, we will additionally use the following data for analytical purposes:

• your role at the company
• registration date
• name of company, entity, account number
• type of company
• order designation
• net price entitlement
• sales organization

This tool does not use your first name and last name or IP address. The data collected by this tool are processed solely for the purpose and to the extent necessary to carry out analyses and to optimise Online Support. The information collected and analysed is not transferred to third parties outside the SEW Group and is stored exclusively on our servers located in the European Union. The period of retention and processing is up to 5 years.

To the extent that the tool uses analytical cookies, their use takes place exclusively after obtaining the user’s consent via the Cookies Management Panel. If you do not wish analyses to be carried out while using the Online Support tool via your device, please change the relevant settings for the analysis of the use of Online Support, in particular via the Cookies Management Panel.

Microsoft Clarity

We use the Microsoft Clarity tool on our website to analyse how the website is used and to improve its functionality and usability (UX analysis). This tool enables the creation of aggregated statistics relating to user behaviour on the website, including heatmaps, session recordings and information on interactions with website elements.

When using Microsoft Clarity, technical and statistical data may be processed, such as information about the device, browser, operating system, screen resolution, visit duration, events on the website, as well as the IP address, which is processed in a truncated (masked) form. These data are not used by the Controller to directly identify the user.

Microsoft Clarity uses cookies and similar technologies, which are applied only after obtaining the user’s prior consent, expressed via the Cookies Management Panel. Data obtained using this tool are processed solely for statistical analysis purposes and for the optimisation of the website’s operation.

The provider of the Microsoft Clarity tool is Microsoft, which may process data using infrastructure located outside the European Union. In such cases, data processing is carried out in accordance with applicable data protection regulations and the mechanisms applied by Microsoft to ensure an adequate level of data protection.The legal basis for the processing of personal data in connection with the use of the Microsoft Clarity tool is the user’s consent, expressed in accordance with Article 6(1)(a) of the GDPR, via the Cookies Management Panel.

The user may withdraw the consent granted for the use of analytical cookies, including Microsoft Clarity, at any time via the Cookies Management Panel, without affecting the lawfulness of processing carried out prior to the withdrawal of consent.

Functions for advertising purposes

Below is an overview of the functions that we carry out with your consent, granted at the start of using the website. These functions are used for advertising purposes and rely on marketing cookies.

For marketing purposes, we use functions that use cookies, for example to tailor advertisements to the interests of website visitors. They are also used to limit the frequency of impressions and to measure the effectiveness of impressions.

Marketo

On our website, we continue to use the service of Marketo Inc (‘Marketo’). In this context, cookies stored on your device are used to enable the analysis of how our website is used.

For this purpose, we create a pseudonymised user profile, with your IP address being anonymised. We then analyse how you use our website and, based on your interests, tailor the advertising content presented to you. At the same time, we regularly optimise our online offering and website content in order to make it increasingly relevant and attractive to users.

Information generated by cookies regarding your use of this website is transmitted to and stored on Marketo servers located within the European Union. To safeguard these processes, the Cloudflare service is also used, which manages certificates for Marketo (e.g. SSL certificates) and distributes request loads across servers in order to enhance the security and performance of the websites (load balancing).

In individual cases, data relating to advertising applications may also be transferred to and stored on servers located in the United States. In such cases, data transfers are carried out on the basis of standard contractual clauses (SCCs) and additional data protection safeguards. We have concluded standard contractual clauses with Marketo and Cloudflare in order to ensure an adequate level of data protection in the third country.

The processing of personal data for the purposes of Marketo functions is based on your consent in accordance with Article 6(1)(a) of the GDPR.

You may withdraw your consent to the processing of your data at any time (without affecting the admissibility of the processing up to that point) through the Cookies Control Panel.

LinkedIn Insight Tag

You may withdraw your consent to the processing of your data at any time (without affecting the admissibility of the processing up to that point) through the Cookies Control Panel.

LinkedIn Insight Tag

Our website uses the LinkedIn Insight Tag (or LinkedIn Pixel) provided by LinkedIn Ireland Unlimited Company (“LinkedIn”). By enabling this JavaScript tag, interest-based advertisements (“Ads”) tailored to you may be displayed when you visit the LinkedIn social network or other websites that also use this technology. At the same time, we receive statistics relating to website visitors and demographic data. In addition, we may assess your interaction with our LinkedIn advertisements and your interest in our offers, including through conversion tracking, and display retargeting information on other websites.

By enabling the LinkedIn Insight Tag, your browser automatically establishes a direct connection to LinkedIn’s servers, both when visiting the LinkedIn website and websites that have implemented the LinkedIn Insight Tag. LinkedIn and we are jointly responsible for collecting user data during visits to our website and transmitting such data to the service provider. Once the data have been transmitted, LinkedIn is solely responsible for their further processing for the purposes described. We have no influence on the extent and manner of LinkedIn's use of your data. To the best of our knowledge, by activating the LinkedIn Insight Tag, LinkedIn receives information that you have visited a specific page of our website or clicked on an advertisement originating from us. If you are registered with LinkedIn, this information may be assigned to your LinkedIn account. Even if you are not registered with LinkedIn or are not logged in, it is possible that LinkedIn may obtain your IP address, time frame and other identifiers and associate them with your activities.

Deactivation of the LinkedIn Insight Tag and advertising settings is possible via your LinkedIn account settings and through the Cookies Management Panel.

Further setting options and information about the LinkedIn Insight Tag can be found in the LinkedIn Privacy Center.

The legal basis for the processing of your data in connection with the LinkedIn Insight Tag is your consent, given in accordance with Article 6(1)(a) of the GDPR. You may withdraw your consent at any time via our Cookies Control Panel.

For more information on LinkedIn's data processing, please contact the service provider: LinkedIn Ireland Unlimited Company, Attn: Legal Dept. (Privacy Policy and User Agreement), Wilton Plaza, Wilton Place, Dublin 2, Ireland; LinkedIn Insight-Tag Information; Privacy Information.

YouTube

On selected pages of our website, we have embedded YouTube videos which are hosted on our SEW-EURODRIVE Polska - YouTube channeland can be played directly. These videos are integrated using the ‘enhanced data protection mode’, meaning that, as a rule, no data used for advertising personalisation are transferred and no YouTube cookies are stored until you play a video. Data are transmitted only when the video is played. We have no influence over this data transfer.

When playing an embedded video, YouTube receives information that you have accessed the corresponding page of our website. In addition, further data may be transmitted to YouTube, of which we have no knowledge. This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no such account exists. If you are logged in to YouTube, your data are directly assigned to your account. If you do not wish this assignment, you should log out of YouTube before activating the video. YouTube stores user data as user profiles and uses them for advertising, market research and/or the optimisation of its website. Such analyses may be carried out in particular (including for users who are not logged in) in order to deliver tailored advertising and to inform other YouTube users about your activities on our website. You may withdraw your consent to such data processing at any time, in particular via your Google account settings or the Cookies Management Panel.

User data may be processed by Google (Google Ireland Limited or Google LLC) as an independent controller providing the YouTube service, including through the use of infrastructure located outside the European Union, in accordance with the Google privacy policy applicable to YouTube. There you will find further information on your rights and available settings to protect your privacy.The legal basis for the processing of your personal data in connection with the playback of YouTube video content is your consent, given in accordance with Article 6(1)(a) of the GDPR. You may withdraw your consent at any time via the Cookies Management Panel.

II. 8. Google Maps

Our website uses the Google Maps service offered by Google (Google Ireland Limited or Google LLC) via an API. In order to use the Google Maps functionalities, it is necessary to process your IP address and other usage data. User data may be processed using infrastructure located outside the European Union, in particular in the United States. We have no influence over the extent or manner of data processing carried out by Google. Google may combine usage data with other data and, if you are logged in to a Google account, associate them with your account. The use of Google Maps serves to present our online offerings in an attractive manner and to enable easy identification of the locations indicated on the website. The legal basis for the processing of data is the user’s consent, given in accordance with Article 6(1)(a) of the GDPR.

Use of the Google Maps service is only possible after obtaining the user’s consent, which can be withdrawn at any time via the Cookie Management Panel.

For more information on the processing of your user data, please refer to Google's privacy policy.

II. 9. SEW-EURODRIVE profiles on social networks

a) Facebook Fanpage

For the information services offered here, we use the technical platform and services of Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For the purposes of this section, the term “Facebook” refers to the social networking service operated by Meta Platforms Ireland Limited. Please note that you use our Facebook page and its functions at your own responsibility. This applies in particular to the use of interactive features (e.g. commenting, sharing, rating).

When you visit our Facebook page, Facebook records, for example, your IP address and other information available via cookies stored on your device. This information is used to provide us, as the operator of the Facebook page, with statistical information on the use of the Facebook page (Facebook “Insights”). Facebook provides further information via the following link.

The data collected in this context are processed by Meta Platforms Ireland Limited and, where necessary, transferred to countries outside the European Union, in particular to the United States. Your data may be transferred to third countries in accordance with applicable data protection mechanisms, in particular standard contractual clauses.

Facebook has its own guidelines describing how your data are used. There, you can also find information on how to contact Facebook and on your advertising settings. The full data use guidelines can be found at the following link. Information on how to manage or delete the information you have can be found on the Facebook support pages.

The manner in which Facebook uses data when you visit Facebook pages for its own purposes, the extent to which activities on the Facebook page are attributed to individual users, how long Facebook stores such data and whether data from your visit from the Facebook page are transferred to third parties, has not been explicitly and clearly defined by Facebook and are not known to us. Facebook's data processing may vary depending on whether you are registered and logged in to Facebook or whether you visit the website as an unregistered and/or unlogged user.

When you access the website or post on Facebook, the IP address assigned to your device is transmitted to Facebook. According to data provided by Meta, this IP address may be anonymised or shortened and processed for a limited period of time. Facebook also stores information about users’ devices (e.g. as part of ‘login notification’ function). Where applicable, Facebook may associate IP addresses with individual users. If you are logged in to Facebook, a cookie containing your Facebook identifier is stored on your device. This allows Facebook to track that you have visited a specific page and how you have used it. This also applies to other Facebook pages. Facebook buttons embedded on websites enable Facebook to record visits to those websites and associate them with your Facebook profile. These data may be used to display content or advertisements tailored to your interests.

If you wish to avoid or limit the data processing by Facebook described above, you should log out of Facebook or deactivate the ‘stay logged in’ function, delete the cookies on your device and restart your browser. This deletes information from Facebook that can directly identify you. This allows you to use our Facebook page without revealing your Facebook ID. When you access the interactive functions of the website (likes, comments, sharing, message, etc.), the Facebook login screen appears. Once you have logged in, you are again recognised by Facebook as a specific user.

The aforementioned purposes of using Facebook constitute our legitimate interest in processing your data. As the provider of the information service, we process only such data relating to the use of our Facebook page that you provide to us and that require interaction. If you submit a question that can only be answered by e-mail, we store your data in accordance with the general data processing rules described in this privacy policy. The legal basis for the processing of your data on our Facebook page is Article 6(1)(f) of the GDPR. The above-mentioned purposes of using Facebook constitute our legitimate interest. With regard to data processing by Meta for analytical and advertising purposes, the legal bases are determined by Meta as an independent controller.

In order to exercise your rights as a data subject, you may contact either us or Facebook. If one party is not responsible for responding or if information must be obtained from the other party, the request will be forwarded accordingly. For questions relating to profiling, data processing when using the Facebook service and Facebook Insights, please contact Facebook directly (see link above). For questions relating to the processing of your interactions with us on our Facebook page, please contact us at rodo@sew-eurodrive.pl.

If you have any questions regarding our information offering, please contact us using the contact details provided above. More information on the operation of the page and the information offering can be found at the following web address.

b) Presence on other social media platforms

We also have a presence on the following social media, run by other service providers:

To provide these information services, we use the technical platforms and services of the respective providers. Please note that you use our presence on social media platforms and their functions at your own responsibility. This applies, in particular, to the use of interactive features (e.g. commenting, sharing, rating). According to information provided by social media platform operators, when visiting their services, data such as the IP address of your device and other data stored on your device in the form of cookies may be processed. The scope and purposes of such processing are determined independently by the platform operators. This information may be used to provide us, as the profile operator, with aggregated statistical information regarding user interactions with our content.

In this respect, the principles described above for Facebook also apply. In particular, user data may be transferred to third countries in accordance with applicable personal data protection mechanisms, in particular standard contractual clauses. With regard to statistical data processed within analytical tools provided by social media platforms (e.g. Insights), SEW-EURODRIVE and the platform providers may act as joint controllers as understood in Article 26 of the GDPR, in accordance with the principles defined by the platform providers. We do not have full knowledge of how social media platforms use data from your visits and interactions with us for their own purposes, how long such data are stored, or whether they are transferred to further recipients. Data processing may vary depending on whether you are registered with and logged in to the social network or visit the page as an unregistered and/or unlogged user. When accessing a post or an account, the IP address assigned to your device is transmitted to the social media platform provider. If you are currently logged in as a user, a cookie stored on your device may be used to track how you navigate the platform. If you wish to avoid this, you should log out, delete cookies stored on your device and restart your browser.

In addition, as the provider of the information service, we process only those personal data that you provide to us in the course of interacting with our profile and that require such interaction. If you submit a question that can only be answered by e-mail, we store your data in accordance with the general data processing principles described in this privacy policy. The legal basis for the processing of your data by SEW-EURODRIVE in connection with the operation of social media profiles is Article 6(1)(f) of the GDPR. The above-mentioned purposes of using social media platforms constitute our legitimate interest. With regard to the processing of user data by social media platform operators for their own purposes (in particular analytical and advertising purposes), the legal bases for processing are determined by those operators acting as independent controllers.

You can contact either us or the relevant social media provider to exercise your rights as the data subject. If one party is not responsible for responding or must receive information from the other party, we or the provider of the social media platform will forward the query to the relevant other party. Please contact the provider of the social media platform directly for any queries concerning the creation of a profile or the processing of your data when using the website. If you have any questions regarding how we process your interaction with us on this website, please do not hesitate to contact us at rodo@sew-eurodrive.pl.

In their data protection policies, the providers describe what information the social media platform receives and how this is used (see table above for the link). These policies also provide information about how to contact them and how to change your advertising settings.

II. 10. Registering, ordering and downloading other online services and offers

On our websites, we also offer services such as downloading white papers, ordering tickets to trade fairs, registering for online events and newsletters. To provide these offers and services, we use solutions and services from Marketo. In this context, please also refer to Marketo's Data Protection Provisions (section II. 7 of the Policy).

a. Ordering a trade fair ticket

If you wish to visit us at a trade fair, you may order a ticket online. The information entered in the form is transferred to SEW-EURODRIVE and processed solely for the purpose of processing the ticket order and organising contact during the event. In particular, the following data are processed:

• name, surname (required information)
• e-mail address (required information)
• company name (required information)
• your department (required information)
• your position in the company (required information)
• street name, house number, postal code, city/town (voluntary)
• academic title (voluntary)
• country/region (voluntary)
• industry (voluntary)
• telephone number (voluntary)
• cell phone number (voluntary)

For the purpose of processing your order and delivering your trade fair ticket, as well as providing you with a suitable SEW contact person to answer your questions on site during the trade fair, we require you to provide the information marked as required. The processing of these data is carried out for the purpose of taking steps at the request of the data subject prior to entering into a contract or for the performance of a contract, pursuant to Article 6(1)(b) of the GDPR. Irrespective of the above, in the event of the pursuit or defence of potential claims, personal data may also be processed on the basis of the controller’s legitimate interest, i.e. pursuant to Article 6(1)(f) of the GDPR.

We process and store the data to the extent and for the period required for the purpose of processing the ticket order and achieving the purpose.

b. Downloading information materials (e.g. white papers)

We offer information materials (e.g. white papers) relating to various topics and SEW-EURODRIVE products for free download from our website in order to enable you to learn more about us and our products (special offer).

The information you enter in the form is transferred to SEW-EURODRIVE and processed for the purpose of providing the information materials and conducting communication related to their download. In particular, the following data are processed:

• e-mail address (required information)
• academic title (voluntary)
• name, surname (voluntary)
• company name (voluntary)
• street name, house number, postal code, city/town (voluntary)
• industry (voluntary)
• department, position in the company (voluntary)
• telephone number (voluntary)
• cell phone number (voluntary)

Your e-mail address is essential for us to be able to send the information materials by e-mail. The processing of data takes place in connection with the voluntary use of the information materials download form. We process and save the data to the extent and for the duration necessary to achieve the stated purpose. The processing of personal data is based on the user’s consent, given by voluntarily completing and submitting the information materials download form. Personal data may be transferred internally to the relevant SEW-EURODRIVE department in order to provide additional information related to the downloaded materials; such contact is carried out exclusively within the scope related to the user’s enquiry.

c. Webinars and online events

We offer webinars and online events on our website. We process the information that you enter in the form. In particular, the following data are processed:

• name (required information)
• surname (required information)
• e-mail address (required information)
• company name (required information)
• department (required information)
• position (required information)
• acad. title (voluntary)
• country/region (voluntary)
• industry (voluntary)
• telephone number (voluntary)
• cell phone number (voluntary)

The information marked as required is necessary to organise and conduct the webinar or online event. In particular, we require your e-mail address, first name and last name, department and position in the company in order to send you, by e-mail, an invitation link together with personalised additional information. The information marked as required is necessary to organise and conduct the webinar or online event, including the provision of organisational information and the link enabling participation in the event. The processing of personal data provided as part of registration for a webinar or online event is carried out on the basis of the user’s consent, given by voluntarily completing and submitting the registration form.

Furthermore, we process and store the data to the extent and for the duration necessary to conduct the webinar or another event.

Data are processed and stored to the extent and for the period necessary to organise and conduct the webinar or online event, and subsequently in accordance with applicable retention periods.

III. Purposes and means of processing data of customers and users of the SEW-EURODRIVE websites

III. 1. Scope and purpose of data processing

a) Performance of the agreement

SEW-EURODRIVE processes personal data received from you in the context of requests for quotations, actions taken prior to entering into an agreement or existing contractual relationships. In particular, this includes contact data, the content of correspondence (including e-mails), data relating to orders, requests for quotations, suggestions regarding our products and billing data. Data processing is carried out on the basis of Article 6(1)(b) of the GDPR. Where a business relationship exists, you are obliged to provide personal data which is necessary for the preparation or execution of the agreements or which we are legally obliged to process. Otherwise, we will not be able to perform such agreements.

We process the information indicated below using our CRM systems, including systems maintained within infrastructure located in Bruchsal. In addition, we use cloud solutions offered by a third-party service provider acting as a processor, whose data centres are located within the European Union.

The scope of processed information may include, for example: last name first name, nickname, form of address, academic title, business e-mail address, business telephone and fax numbers, selected communication language, content of granted marketing consent, date of creation and modification of CRM entries and the change history of such entries, an overview of interactions (telephone calls, visits, meetings, etc.), an overview of incoming and existing orders, and your function/role within the company.

In addition, we may process the following information:

• the content of a power of attorney or the scope of your authorisation to act on behalf of the company, including information resulting from submitted documents, statements or established cooperation practices, to the extent necessary for the handling of the business relationship;
• your position and decision-making authority within the company; i.e. based on your function and the presumed or documented scope of your authorisation, we identify the role and scope of competencies resulting from the performed function or documented authorisation in accordance with our internal methodology;
• statistical information concerning the frequency of contacts and operational events (e.g. enquiries, service requests), processed solely for the purpose of organising customer service;
• preferred form of contact;
• voluntarily provided opinions or feedback relating to products, services or cooperation with SEW-EURODRIVE, processed exclusively for the purpose of improving service quality, without profiling natural persons and without automated decision-making;
• contact person at SEW-EURODRIVE,
• project organisation chart;
• your association, as the contact person, with leads and business opportunities,
• your association as a contact person with a customer of SEW-EURODRIVE together with your business address;
• URLs to your profiles on social media profiles, provided voluntarily or publicly available and used exclusively for contact purposes within the business relationship;
• information from the Online Support platform including service tickets;
• internal assignment of customers to informational campaigns in B2B relations, provided this is in accordance with applicable law and granted consents.

Opinions and feedback referred to above are optional, are not used to assess natural persons or assign characteristics to them, and their processing is independent of the CRM systems used to manage commercial relationships.

We process the above information for the purposes of customer service and more efficient execution of orders and assignments. Our service personnel require this information for contact purposes and, where applicable, for fault removal. Accordingly, the processing of this information is necessary for the proper performance of the concluded agreement and for ensuring efficient communication and fulfilment of contractual obligations. Data processing within the performance of the agreement includes the use of data for the provision of services covered by the agreement, including service activities under service agreements or the handling of warranty claims. In addition, in the context of financing enquiries, SEW may use data necessary to present an offer and, exclusively to the extent required for handling such an enquiry, transfer such data to its business partners. Further details on processing purposes can be found in the relevant contractual documents.

The legal basis for the described processing is primarily the performance of the agreement pursuant to Article 6(1)(b) of the GDPR. To the extent that data processing is not directly necessary for the performance of the agreement but serves to ensure proper customer service, communication and the pursuit or defence of claims, the legal basis is Article 6(1)(f) of the GDPR. These purposes constitute the controller’s legitimate interest.

External lawyers, tax advisors and auditors may, for the purposes of advisory and audit services, obtain access to information and documents relating to our cooperation. We do not publicly disclose the names of external cloud service providers in this privacy policy in order to limit IT security risks, including unauthorised access to systems and personal data. Upon request by the data subject, we will indicate categories of data recipients or, where required under the GDPR, specific recipients to whom data have been disclosed. SEW-EURODRIVE data centres and those of third-party cloud providers are located within the European Union. Access to CRM data is also granted to employees of sales and customer service departments for transaction processing purposes, as well as to personnel maintaining our IT and cloud systems and providing support services. We have concluded data processing agreements with third-party providers processing personal data on our behalf in accordance with Article 28 of the GDPR. In other cases, data are transferred on the basis of applicable law or disclosed to independent controllers.

SEW-EURODRIVE processes and stores your personal data (within local systems and cloud solutions) to the extent and for the period necessary to establish, perform and terminate the business relationship, as well as for the period required to assert or exercise rights or to defend against claims (in particular relating to deliveries, payments, guarantees, warranties or compensation). Personal data whose further storage is required under applicable law, in particular tax, accounting or bookkeeping regulations, are stored for the periods resulting from such regulations and subsequently deleted or anonymised. All other personal data are deleted immediately after the purpose of processing ceases to apply, unless further processing is based on this privacy policy or applicable law. Processing of personal data for the performance of contractual obligations, including the handling of warranty claims, is carried out pursuant to Article 6(1)(b) of the GDPR. Where processing is not directly necessary for the performance of the agreement but serves to ensure proper customer service, operational communication or the pursuit or defence of claims arising from the agreement, the legal basis is Article 6(1)(f) of the GDPR. Data processing in order to comply with legal obligations is carried out pursuant to Article 6(1)(c) of the GDPR.

b) Verification of address and credit worthiness

To verify your address and creditworthiness, SEW-EURODRIVE verifies the address details of your company and, where permitted by applicable law, information relating to its payment reliability, including information determined using mathematical and statistical procedures (scoring). The result of such an assessment does not constitute the sole basis for decision-making and is in each case reviewed by authorised SEW employees. This takes place where SEW may be exposed to an economic risk following the conclusion of an agreement and seeks to prevent such risk by verifying creditworthiness. On the basis of these data, SEW may grant trade credit for the delivery of goods or services. For the purposes of assessing creditworthiness, we may use the services of professional entities (credit agencies).

Information obtained from credit agencies and internal information on payment behaviour are evaluated internally by SEW-EURODRIVE, resulting in an internal rating that serves as the basis for granting a credit limit. Data relating to creditworthiness assessment and payment history are stored for a period not exceeding 5 years from the end of the commercial cooperation or from the last delivery of goods or provision of services. The processing of data is carried out on the basis of Article 6(1)(f) of the GDPR, i.e. on the basis of the controller’s legitimate interest in safeguarding SEW’s economic interests and enabling the delivery of goods and the provision of services.

c) Promotional use of data by SEW-EURODRIVE

SEW-EURODRIVE and engaged service providers (e.g. printing companies) use your name and business address as a contact person within the framework of ongoing business contacts and activities aimed at maintaining business relationships. Advertising uses include the postal dispatch of advertisements for our products and services. Last but not least, we would like to stay in touch with you on special occasions and send you Christmas greetings, for example. SEW uses your telephone number or e-mail address for direct marketing purposes only where prior consent has been given, in accordance with Article 6(1)(a) of the GDPR and the applicable

SEW-EURODRIVE may process data obtained in connection with maintaining business relationships (such as contact details and information on purchased products or services), as well as data collected when using offers or services on the website, at trade fairs or during other promotional activities, for the purpose of creating general marketing profiles and preparing personalised offers, provided that such profiling does not produce legal effects concerning you nor similarly significantly affect you.

We may also send you – as an existing customer or where we have otherwise received your contact details - information by post about special activities, events or trade fairs within the framework described above. Where you have given prior consent, you may receive an e-mail containing information about a specific campaign, how to participate and what information is required. We may also register your participation via an event-related website and process your data for the specified purposes, for example to provide offered products or send information. Information obtained in this context may be used within the scope of the processing described herein. Your data are processed on the basis of Article 6(1)(f) of the GDPR, where the use of contact data via electronic communication channels takes place exclusively in accordance with separate legal provisions governing direct marketing. Where participation in a campaign involves registration, your data are processed for the performance of a contract pursuant to Article 6(1)(b) of the GDPR.

Personal data processed for advertising purposes are stored within the European Union. We may use carefully selected and audited service providers. Where, in individual cases, data are transferred to and processed on servers in third countries outside the EU/EEA, in particular the United States and, where applicable, the United Kingdom, this takes place using commissioned and monitored service providers who have agreed to ensure an adequate level of data protection and with whom standard contractual clauses approved by the European Commission have been agreed. In exceptional cases where no other data protection mechanism can be applied, data transfers may take place pursuant to Article 49 of the GDPR, in particular for the performance of a specific contract or on the basis of the explicit consent of the data subject.

Personal data collected for advertising purposes are processed for the duration of the business relationship or until an objection to processing for marketing purposes is raised. Exceptions apply where consent allows for longer use and/or where data are subject to statutory retention obligations. In the latter case, erasure takes place after the expiry of the legally required retention period. You have the right to object to the processing of your data, as described in section XI, which may result in a shorter processing period.

The legal basis for processing data for advertising purposes is Article 6(1)(f) of the GDPR or, where consent has been granted, Article 6(1)(a) of the GDPR.

d) Processing of personal data due to legal obligations

SEW-EURODRIVE, like any company operating in Poland and Europe, is subject to various legal obligations, including obligations to verify data relating to our customers and business partners. In such cases, we process personal data only to the extent necessary to fulfil these legal requirements. For the purpose of complying with legal obligations, automated processing of personal data may take place solely to provide technical support for verification or control processes. Such processing is auxiliary, and all decisions are always made by authorised SEW employees and are not based exclusively on automated processing, including profiling, as defined in Article 22 of the GDPR. Unless you are expressly informed otherwise, no automated decisions producing legal effects concerning you or similarly significantly affecting you are made as part of this processing. The legal basis for such processing is Article 6(1)(c) of the GDPR in conjunction with the relevant legal provisions.

These legal provisions relate to, in particular:

• prevention of fraud and money laundering
• tax auditing and reporting requirements
• evaluation and management of risks in the Group
• sanctions lists
• export control, customs regulations
• auditing, in particular by tax consultants and auditors

e) Extraction of data from publicly available sources to update CRM data

Pursuant to Article 5(1)(d) of the GDPR, personal data must be accurate and kept up to date. We aim to ensure that your contact data stored in our database / CRM (on our local servers and in the cloud) are always up to date, so that, in the course of service provision, both you and our employees can efficiently perform contractual obligations and communicate with each other.

To ensure data accuracy, we use automated tools for the technical extraction and updating of contact data, which are not used for profiling natural persons or for making automated decisions concerning them. Using these technologies, we collect exclusively business-related contact data, without processing data relating to the private sphere or activities unrelated to the professional role, and subsequently import such data into our CRM. In particular, the following data may be processed: form of address, last name, first name, business e-mail address, business telephone number, business address, role and department within the company, company name, URL of a social media profile, URL of a messenger used for business communication (where publicly provided by the data subject), and other information contained in business cards and e-mail signatures.

Access to the data is granted to employees who have access to our CRM. At the moment, information from publicly available sources is obtained, inter alia, using the SnapAddy tool and then imported into our CRM (on local servers and in the cloud). We have concluded a data processing agreement with the provider of the SnapAddy tool. Our data centres, SnapAddy’s data centres and cloud service providers are located within the European Union. Since the information is imported into our CRM, the retention period depends on the retention period applicable to such data in the CRM (see section III.1(a) above).

We carry out the above activities on the basis of Article 6 (1)(f) of the GDPR in conjunction with Article 5(1)(d) of the GDPR, i.e. the principle of data accuracy and data updating. The purposes listed above constitute our legitimate interest in processing the data. In this case, you have the right to object to the processing; further information is provided in section XI.

III. 2. Distribution of data within the SEW-EURODRIVE Group

SEW-EURODRIVE may transfer and, where necessary, update your master data (company name, contact person, address and contact details such as telephone number and e-mail address) to other companies within the SEW-EURODRIVE Group in order to ensure that all SEW-EURODRIVE Group companies involved in a given process (e.g. performance of an agreement) have access to the same personal data provided by you. This is intended to simplify our processes and may relieve you from the need to repeatedly provide the same master data when contacting another company within the SEW-EURODRIVE Group. Such processing is carried out on the basis of Article 6(1)(f) of the GDPR. Our legitimate interest consists in ensuring consistent customer service, efficient business processes and reducing the need for repeated collection of the same data within the Group. Where the transfer of data takes place in connection with the performance of an agreement, the data are transferred on the basis of Article 6(1)(b) of the GDPR. Your rights are safeguarded by internal contractual arrangements ensuring a high level of data protection. Only data necessary for the performance of a given business process are transferred, in accordance with the data minimisation principle referred to in Article 5(1)(c) of the GDPR.

Furthermore, in addition to the master data, other companies within the SEW-EURODRIVE Group may receive the information necessary to prepare an order. For example, different SEW-EURODRIVE products are manufactured by different SEW-EURODRIVE companies, so data transfers may take place in order to simplify order processing and delivery. In such cases, you will be informed of the data transfer at the latest at the time of conclusion of the agreement or immediately thereafter. The legal basis for such processing is Article 6(1)(b) of the GDPR.

If your company is located outside the territory of Poland, a company affiliated with us within the SEW-EURODRIVE Group that is competent for the registered office of your company may be responsible for handling your service, contracts or enquiries. In such cases, that company processes your personal data on the basis of the concluded agreement, i.e. pursuant to Article 6(1)(b) of the GDPR.

The processing operations referred to above may result in your master data being processed by SEW-EURODRIVE companies outside of the European Union (EU) or European Economic Area (EEA). In cases where the EU Commission has not issued an adequacy decision for a given third country, we apply appropriate legal safeguards, in particular standard contractual clauses adopted by the European Commission, and assess the level of data protection in the respective country. You can find a list of the companies belonging to the SEW-EURODRIVE Group here. The data are subject to the same retention and deletion rules as described above in this privacy policy.

III. 3. Surveys with online tools

We may process your personal data in connection with conducting surveys or polls with customers in order to learn more about customer requirements relating to our products and services. For this purpose, we may invite you to participate in a survey; participation is always voluntary.

When you participate in a survey, your responses are processed in a pseudonymised manner and analysed exclusively in the form of aggregated statistical summaries. In addition, we may store your personal data, such as your e-mail address, in order to invite you to participate in surveys; such data are processed independently of the survey results. We also store information indicating that you have participated in a survey in order to prevent multiple participation and potential distortion of results. This information is stored separately from the content of the responses and from your e-mail address and is not combined with other data.

Survey responses are collected and analysed statistically in such a way that attribution of responses to individual participants is not possible. We also ensure that survey questions are designed so as to prevent the identification of individual respondents. In some cases, participation in a survey may be linked to a competition or other incentives; however, this is carried out in such a way that responses are strictly separated from incentives and cannot be linked to them. In addition, we can display individual design elements such as images, videos, questions or pages individually. When carrying out surveys and research, we use the SurvGo tool and the LamaPoll service, which are provided by external service providers acting as our processors. These providers are duly verified by us. Further information on data processing can be found in the providers’ privacy policies, Privacy Policy (survgo.com), Privacy Policy (lamapoll.de). These entities process data solely on our documented instructions and do not use them for their own purposes.

The legal basis for processing your contact data for the purpose of inviting you to participate in surveys is Article 6(1)(f) of the GDPR, i.e. the controller’s legitimate interest in conducting customer satisfaction research and improving products and services. The legal basis for processing your data during participation in a survey is also Article 6(1)(f) of the GDPR. Our legitimate interest consists in conducting customer satisfaction research, analysing the quality of products and services and further developing them, while ensuring that participation is voluntary and does not result in any negative consequences for participants. The data are processed exclusively to ensure the reliability and integrity of survey results and are not used for other purposes.

Where data are processed on the basis of Article 6(1)(f) of the GDPR, you have the right to object to such processing in accordance with the principles described in section XI.

IV. Data protection information for suppliers and subcontractors

a) Establishment, performance and termination of the supply agreement / transaction

For the purpose of carrying out internal and external tasks, projects and transactions, SEW-EURODRIVE procures goods and services from various suppliers and subcontractors worldwide. In order to conclude, perform and terminate supply/support transactions, as well as to carry out professional activities, it is necessary (purpose of the processing) to exchange information between SEW-EURODRIVE employees and contact persons of suppliers/subcontractors. Such information is exchanged by post, telephone or electronically (e.g. by e-mail) and is processed and stored in appropriate analogue and digital supplier management systems and databases.

The following data are processed: first name, last name, (business) e-mail address, telephone number, mobile phone number, role/function within the company, delivery address and postal address, information from quotations, order confirmations, contracts and invoices, qualifications and certificates, contents of information forms, notes from conversations, as well as information from verbal, telephone or electronic correspondence.

SEW-EURODRIVE processes the above-listed information in paper and digital form on servers located in Bruchsal (Germany). The need-to-know principle applies. Statutory auditors, tax advisors, lawyers, social insurance institutions as well as supervisory and investigative authorities may access such information to the extent and for the period provided for by law and strictly necessary for the performance of their statutory duties. Where necessary, access may also be granted to carefully selected service providers whose involvement is required for proper supplier management (e.g. supplier surveys, supplier audits, supply chain monitoring). These entities obtain access to the data either as independent controllers or on the basis of legal provisions; in other cases, data are processed by entities acting as processors under data processing agreements.

The data are stored to the extent and for the period required for the establishment, performance and termination of the supply/service agreement and for compliance with legal, contractual or internal data retention obligations and timeframes.

To the extent necessary for the establishment, performance and termination of the agreement, the legal basis for data processing is Article 6(1)(b) of the GDPR. In other cases, in particular for ongoing operational and organisational communication with contact persons of suppliers and subcontractors, the legal basis is Article 6(1)(f) of the GDPR, and the purposes described above constitute the legitimate interest of SEW-EURODRIVE.

If cooperation between suppliers and SEW-EURODRIVE involves joint development of orders or joint determination of the purposes and means of data processing (joint controllership as defined in Article 26 of the GDPR), appropriate agreements defining the respective responsibilities of the parties will be concluded with such suppliers.

b) Supply chain monitoring and regular supplier surveys

EU regulations (e.g. REACH, RoHS 1 + 2, Regulation (EU) 2017/821 of 17 May 2017 on conflict minerals), national regulations (e.g. the German Supply Chain Due Diligence Act – LkSG) and international regulations (e.g. the U.S. Dodd-Frank Act of 2010) on transparency require us to carefully select suppliers worldwide and to regularly review supplier relationships, including supply chains, from both a legal and ethical perspective. In addition to binding legal requirements, all SEW-EURODRIVE entities worldwide comply with an internal Code of Conduct. Global respect for human rights, fair working conditions, combating corruption, preventing armed conflicts, supply chain monitoring and environmental protection are core elements of our corporate philosophy.

For the purpose of monitoring our supply chains and preventing the use of raw materials/resources/minerals from conflict-affected and high-risk areas, we conduct annual surveys of our suppliers and supply chains. These surveys are conducted either internally (see section III.3 “Surveys using online tools”) or are commissioned to a specialised service provider, IntegrityNext GmbH, Munich (“IntegrityNext”).

For example, Section 1502 of the U.S. Dodd-Frank Act of 2010 prohibits the use of conflict materials. In order to conduct a survey, we transmit the company name and e-mail address to the IntegrityNext platform, and IntegrityNext then invites the company to complete the survey via its platform. As part of the survey, the following data are generally processed from and about the surveyed person: first name, last name, (business) e-mail address, company name and, in particular, the information entered into the questionnaire.

The data are stored in IntegrityNext’s data centres (AWS) located within the European Union, to the extent and for the period necessary to fulfil the purpose of processing and to comply with legal, contractual or internal retention obligations.

The legal basis for data processing is Article 6(1)(c) of the GDPR, insofar as the processing serves to fulfil legal obligations relating to due diligence and supply chain monitoring, and Article 6(1)(f) of the GDPR in all other cases, i.e. the legitimate interest of SEW-EURODRIVE in ensuring compliance of the supply chain with applicable legal and ethical standards. This also serves the interests of our suppliers, in particular with regard to compliance with applicable legal and market requirements.

No decisions producing legal effects concerning natural persons or similarly significantly affecting them are made solely by automated means as defined in Article 22 of the GDPR as part of these surveys.

V. Purposes and uses of job applicants data at SEW-EURODRIVE

If you apply for a position at SEW-EURODRIVE, the data processing principles described below apply. You will be informed separately about data processing after hiring, at the time the employment contract is concluded.

V.1. Scope of data processing and designated uses

a) Internal data processing when checking your application

We process the data provided as part of your application in order to assess your application and your suitability for the selected position. When reviewing applications for positions in Poland, we may use specialised service providers supervised by us. For the purpose of evaluating your application, we require in particular the following information:

• first name(s) and last name,
• date of birth,
• contact details,
• educational background,
• professional qualifications,
• employment history.

If you apply for a position at SEW-EURODRIVE in another country, additional information may be required in accordance with applicable local law, such as:

• title (required),
• place of birth,
• personal identification data required under applicable labour law (e.g. gender – only to the extent permitted by local law),
• nationality,
• residence or work permit,
• job application photo / profile photo,
• postal and residential address (street, house number, postal code, town/city, country)
• e-mail address and telephone number (landline, mobile)
• diplomas (school, university) and references,
• educational and vocational training,
• certificates of further education and vocational training,
• your qualifications, language skills, personal qualities and other skills,
• your availability,
• preferred type of employment (full-time, part-time, freelance),
• references from previous employers,

The scope of data processed during the recruitment process may also include:

• information provided by you and your conduct during interviews conducted by telephone and/or on site (e.g. educational and professional background, motivation for job change, career aspirations, preferred location, salary expectations, strengths and weaknesses, five-year plan, hobbies and voluntary activities where relevant, notice period with current employer, goals for the future),
• information on what you know about SEW-EURODRIVE and how you learned about SEW-EURODRIVE,
• CV and a cover letter,
• telephone correspondence with comments/notes on the assessment form or notes in the HR system,
• other information contained in the application documents, in particular the curriculum vitae (CV)
• information from publicly accessible professional social networking profiles (e.g. XING, LinkedIn), limited to professional and educational information,
• information provided to us by an external HR service provider commissioned to search for suitable candidates or appointed by you to seek suitable positions, or information exchanged with such a provider (where applicable),
• consent to receive job alerts and professional information from SEW-EURODRIVE worldwide,
• information relating to reimbursement of travel expenses incurred during the application process (e.g. account details),
• depending on the position, additional application questions may be requested in the job application assistant, some of which may be mandatory,
• other data that are voluntarily provided by the applicant during the recruitment process.

SEW-EURODRIVE does not require or expect the provision of special categories of personal data as defined in Article 9 of the GDPR (in particular data concerning health, religious beliefs, political opinions or trade union membership), unless the obligation to process such data arises directly from applicable law.

If you apply via our careers website (online job application assistant) or if we contact you via a social media platform, we process information about you and received from you in our on-premises data centre as well as in our cloud-based HR and recruitment system provided by Oracle. Oracle’s data centre is located in Frankfurt am Main, Germany. SEW-EURODRIVE’s headquarters in Germany has concluded a data processing agreement with Oracle in order to safeguard the transferred and processed information.

Your job application will be forwarded internally to the relevant department.

Please note that in the case of applications for positions outside Poland, the HR and recruitment system is used by SEW subsidiaries worldwide. These subsidiaries may access your candidate profile, including contact details and application documents, via candidate search. Such access is strictly limited to the purposes of the specific recruitment process or future recruitment processes for which you have given your consent.

If you have commissioned, or we have commissioned, an HR service provider to search for vacant positions or suitable candidates, we will exchange the above-mentioned information provided by you and relating to you with the relevant external HR service provider.

The data contained in your job application will be deleted 6 months after completion of the recruitment process (see section III), unless you give your consent for your data to be stored in our candidate database.

The legal basis for the processing of applicants’ personal data is Article 6(1)(b) of the GDPR (steps taken prior to entering into a contract). Where the processing of special categories of personal data is required by law, the legal basis is Article 9(2)(b) of the GDPR.

If you are under 18 years of age, the processing of personal data for the purpose of concluding a contract takes place only with the consent of your legal representative. Any extended storage of your application data (e.g. for participation in future recruitment or internship processes) is also carried out solely on the basis of your consent, for the period specified in the consent or until it is withdrawn, but no longer than permitted under the applicable data retention rules set out in the record of processing activities.

b) Adjustment to open job offers at the SEW-EURODRIVE Group

If you have given your consent, we will, during the recruitment process, assess whether you qualify for positions other than the one you are currently applying for, provided that such positions correspond to your qualifications. The candidate database is maintained exclusively for individuals who have given their explicit consent and for the period specified in the content of that consent or until it is withdrawn. If you do not wish such access at a later date, you may inform us at any time, in any form, by e-mail or in the manner described below (in section XI of this policy). Withdrawal of consent, irrespective of when it occurs, will have no impact on the course or outcome of your current application. The processing of personal data is carried out on the basis of Article 6(1)(a) of the GDPR. Your rights are safeguarded by internal contractual arrangements ensuring a high level of data protection.

c) Saving your application in our talent pool

If you give your consent to the processing of your personal data for the purpose of participation in future recruitment processes, your data will be included in our candidate database. This enables us to contact you if a suitable position becomes available. You can complete the job application form with the consent text here.

Where consent has been granted, we store your recruitment data for the period specified in the consent or until it is withdrawn, but no longer than 3 years, in accordance with the applicable retention rules.

Please note that failure to grant consent means that we will not be able to take your application into account in future recruitment processes conducted outside the current procedure. The legal basis for the processing is Article 6(1)(a) of the GDPR.

V.2. Applications via social media platforms

You can also apply to us using social media platforms (for example Linkedin). Data from the platform is redirected to a dedicated email address: praca@sew-eurodrive.pl in the form of your CV and any other documents you have provided via the platforms. We are not aware of any further details regarding the processing of your data by the platforms. The legal basis is Article 6 (1)(b) of the GDPR.

V.3. Career information and job notifications via email and social media, if applicable

If you have given your consent in each respective case, we will regularly inform you by e-mail about new job vacancies at SEW-EURODRIVE worldwide (job alerts) and/or provide other international career-related information via e-mail and, where applicable, social media (e.g. job offers, job fair dates, events, etc.). For this purpose, we use e-mail and social media campaign tools integrated with our cloud-based Oracle HCM system. We will use these tools to process your first and last name and your e-mail address. The legal basis for the processing of personal data for the purpose of sending job alerts and career information is Article 6(1)(a) of the GDPR (consent).

In order to improve our recruitment processes and enhance the functioning of our careers website, we analyse the effectiveness of our recruitment communication based on aggregated and anonymised statistical data, without identifying specific natural persons. This analysis may include, in particular, the following:

• pipeline growth, i.e. how many potential customers we generated and passed on to the sales team
• conversion rate, i.e. how many leads become customers
• the number of recipients who opened e-mails
• click-through rate, i.e. what percentage of recipients opened the e-mail and clicked on the link in the e-mail
• form conversion rate, i.e. the percentage of e-mail recipients who completed the form
• rejection rate, i.e. how many e-mails were not delivered
• unsubscribe rate, i.e. how many people unsubscribed from email notifications
• unique visitors, i.e. how many people visit the careers page
• returning visitors, i.e. how many people visited our careers page / website in a certain period of time
• page views, i.e. how many people visited our careers page / website
• search engine traffic, i.e. how many people arrived at our careers page / website using a search engine
• rejection rate, i.e. how many people visit the careers page / website and leave without taking further action
• links from other sites / backlinks, i.e. whether there are other websites redirecting to our site

The above indicators are exclusively aggregated and statistical in nature and are used solely to evaluate the effectiveness of recruitment communication and the development of the careers page. They are not used for sales or marketing activities and do not lead to decisions concerning individual natural persons.

The legal basis for this processing is Article 6(1)(f) of the GDPR, i.e. the controller’s legitimate interest in improving recruitment processes and optimising communication with candidates.

Access to aggregated analysis results is limited exclusively to authorised employees involved in recruitment processes and, where necessary, IT staff responsible for system maintenance. The Oracle HCM data centre is located in Frankfurt am Main (Germany).

You may withdraw your consent at any time by clicking the unsubscribe link included in the e-mail message or by sending an e-mail to: praca@sew-eurodrive.pl.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal (ex nunc effect). Following withdrawal of consent, we will cease sending job notifications and career-related information, and personal data processed exclusively for this purpose will be deleted or permanently anonymised in accordance with applicable data retention rules.

V.4. Applying for internships and work placements

We are pleased to receive applications for internships and work placements. Personal data submitted as part of an internship or work placement application are processed in accordance with the principles described in this section, subject to the provisions set out below.

We process recruitment data solely for the purpose of conducting the recruitment process for internships or work placements, in particular to assess the application, contact the candidate and make a decision regarding admission to an internship or placement. Such data are not included in the candidate pool and are not used for future recruitment processes unless separate consent for further processing is provided.

If the application is unsuccessful, application documents and other recruitment data are deleted no later than 6 months after completion of the recruitment process, unless applicable legal provisions require longer storage or the candidate has consented to extended processing.

The legal basis for processing personal data in connection with internships and work placements is Article 6(1)(b) of the GDPR, i.e. processing necessary to take steps prior to entering into a contract and, where applicable, to conclude such a contract.

VI. Data protection information for visitors of SEW-EURODRIVE

We are pleased when you visit us on site - whether as a contact person of a company (such as a customer or supplier), as a prospective customer, job applicant or employee from SEW- EURODRIVE Group locations around the world. In order to be able to quickly identify the respective location in the event of an incident at one of our facilities or business premises, to track visits for the purpose of asserting or defending claims, to protect our business and trade secrets and, where separate consent has been granted, to facilitate future visits or marketing contact, we record the following visitor information in digital form in an internal IT system.

For the purposes indicated above, we process:

• surname, name,
• company name together with an address,
• (business) telephone number (optional),
• (business) e-mail address (optional),
• contact person of SEW-EURODRIVE,
• date and time of arrival and departure.

The legal basis is Article 6(1)(f) of the GDPR. The above purposes constitute our legitimate interests.

Visitor data are stored depending on the processing purpose:

• up to 24 hours – for ensuring on-site safety
• up to 5 years from the last visit or until consent is withdrawn – for facilitating future registrations
• up to 3 months, or for the duration of legal proceedings and limitation periods – for asserting or defending claims
• until consent is withdrawn or a valid objection is raised – for direct marketing purposes

After expiry of these periods, data are deleted or anonymised unless further retention is required by law.

VII. Data protection information on the processing of personal data in connection with trade fairs and other events

If you visit us at a trade fair or other networking event, we may exchange information about our products or about existing or future collaboration, as well as establish, initiate, develop, or conclude business relationships and business transactions.

Depending on the nature of the contact and the scope of the information provided by you, we may process the following personal data: first name, last name, form of address, title, (business) telephone number, (business) e-mail address, company name and address, business unit, position or function held, industry, as well as the content of correspondence conducted before, during or after the trade fair or event (in particular the content of e-mails or electronic messenger communications).

We may also process the following information:

• Information contained on the business cards that we exchange or that you give us;
• Information taken from your (public) website or (public) social media profile;
• Your image / appearance in the form of photographs, audio recordings or video recordings, if photos or recordings are made during a given event for documentation or promotional purposes, and their publication takes place in accordance with applicable rules and, where required, on the basis of separate consent; the principles for processing photographs and videos are described in section VIII;
• Your data recorded and documented in a completed survey; in addition to your name and contact details, this mainly includes answers to questions concerning products and processes, and where the visitor completes the survey using a tablet, the date and time of completion are also recorded;
• Information provided by the visitor that is recorded and documented in a conversation note; in addition to name and contact details, this includes in particular information on the industry, project planning, type of visit (customer, OEM, potential customer, supplier, press, student, job applicant, other service provider), main discussion points, discussion notes, excerpts of statements (verbatim quotes) from conversations, requests for contact (telephone, post, e-mail, messenger), interest in advertising, planned orders, to the extent necessary to conduct business correspondence, prepare an offer or continue a business relationship;
• Other information from our correspondence before, during and after the trade fair.
• Documentation or notation in a conversation note concerning an objection to the processing and storage of data in our IT systems and in paper form.

If you are a new, existing or potential customer, the information provided will be entered and processed into our Customer Relationship Management (CRM) system. The data are processed on SEW-EURODRIVE servers located in Bruchsal and, depending on the solutions used, in the cloud environment of external service providers, in accordance with the principles described in section III.1(a), including provisions concerning data transfers outside the EU/EEA (where applicable).

If you are a supplier, the information is entered and processed in our supplier management system.

If you make contact with us on a professional level, i.e. in the course of performing your profession, personal data are processed on the basis of Article 6(1)(b) of the GDPR, exclusively to the extent that such contact is directly related to activities aimed at concluding a contract or performing cooperation. This is because data processing involving, for example, the exchange of contact details or the initiation of cooperation or a project is necessary for the performance of activities both with regard to our contracting parties and our employees. In all other cases, personal data are processed on the basis of Article 6(1)(f) of the GDPR, i.e. the legitimate interest consisting in establishing and maintaining business relationships and initiating cooperation.

In certain circumstances, for promotional purposes, we create and publish photographs, audio recordings and video recordings from events or trade fairs. We obtain your consent to publish a photograph or video if the image or recording focuses on a specific person (you appear in the foreground). Consent is also required where an interview is conducted and subsequently published or where statements (verbatim quotes) are published in the media. The legal basis in such cases is Article 6(1)(a) of the GDPR. If you are not in the foreground and the photograph or recording depicts multiple persons, the processing of personal data in the form of an image may be carried out on the basis of Article 6(1)(f) of the GDPR, i.e. the controller’s legitimate interest in documenting and promoting events. Please refer to our data protection information concerning the taking and publication of photographs, audio recordings and videos set out in section VIII of this privacy policy.

If you participate in an on-site interview or survey, we are obliged to obtain your prior consent before publishing the interview or survey content containing personal data. The legal basis in such cases is Article 6(1)(a) of the GDPR.

The information is stored for the period necessary to fulfil the purposes described above, in accordance with the applicable retention periods specified in the record of processing activities, and where statutory obligations apply, for the period required by law.

If you are a customer or potential customer, data processing is carried out in accordance with the principles described in section III.1 of this privacy policy. In the case of personal participation in one of our surveys, the data protection information set out in section III.3 applies.

If social media platforms, such as LinkedIn, are used in connection with an event, the data protection information of the respective social media platform must also be followed.

Analytical tools, including Microsoft Clarity, may be used on our website to analyse how the website is used and to optimise its operation.

Data processing in this respect takes place exclusively on the basis of the user’s consent, pursuant to Article 6(1)(a) of the GDPR.

Detailed information on the scope of data processing, the operation of the tool, data transfers to third countries and users’ rights can be found in section II.7(b) of this privacy policy.

VIII. Data protection information for the creation and publication of photo, audio and video recordings as well as press and advertising texts

When participating in one of the events or training sessions organised by us, visiting our trade fair stand or engaging in other forms of personal contact, photographs, audio recordings and video recordings may be taken and published in which you may be recognisable, either in the foreground of the recorded event or as one of many persons depicted. Recording may be carried out directly by us or by an external agency. The purpose of such processing is the promotion of events, the activities of SEW-EURODRIVE and image-building activities, including employer branding. In individual cases, we may conduct conversations or interviews with you, for example in connection with a specific event, our products or cooperation with us, and may subsequently process and publish your statement or excerpts thereof (quotes) as part of press releases. In addition to your external appearance (photograph or video recording) and voice and speech (video and audio recording), we may, depending on the circumstances, also process information such as your first and last name, position in the company, e-mail address or telephone number, for example when referring to you in a press release, social media post or photo caption. Where materials show you in the foreground, we may apply technical organisational markings (e.g. a tag ID) solely for the purpose of organising and managing the materials and enabling their retrieval. Such markings are not used for biometric identification, do not involve automated analysis of facial features and do not constitute profiling as defined in Article 4(4) of the GDPR, nor are they used to compare images with other datasets.

Depending on the form and place of publication of photographs, recordings or press materials containing references to you, access to viewing, listening to, saving, analysing or further dissemination may, as a rule, be available to an unrestricted audience, including persons worldwide with access to the relevant medium.

Publication may take place in particular via the Internet, including on websites, mobile applications and blogs of SEW-EURODRIVE and SEW-EURODRIVE Group companies, in online and printed media (local, regional, supra-regional and international), in printed promotional materials (e.g. brochures and leaflets), on radio and television, on social media platforms (such as YouTube, Facebook, LinkedIn and Instagram), as well as in internal SEW-EURODRIVE media, including the global DriveNet intranet and within newsletters and e-mail campaigns conducted by SEW-EURODRIVE and companies within the SEW-EURODRIVE Group. If photographs, recordings or press releases are published on social media channels, access to such content is granted to all users of the respective platform, in accordance with its terms of use. Likewise, where photographs or recordings are broadcast on radio or television, they may be viewed or listened to by anyone receiving the respective channel or programme. SEW-EURODRIVE has no influence on the further sharing, copying or dissemination of the published materials by third parties.

Where you are depicted in the foreground of a photograph or recording in a manner allowing clear identification of your appearance or voice, and/or where your personal data such as name, position or quoted statement are included in a press release or advertising text, processing of personal data takes place exclusively on the basis of your prior consent. After consent has been obtained, technical organisational markings (tag IDs) may be applied solely for material management and retrieval purposes. The legal basis for such processing is Article 6(1)(a) of the GDPR. You may withdraw your consent at any time in accordance with Article 7(3) of the GDPR, without giving reasons, in particular by sending an e-mail to rodo@sew-eurodrive.pl. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal.

Where consent has been granted without a specified validity period, personal data will be processed until consent is withdrawn or until the data lose relevance in relation to the purpose of processing. Photographs or recordings depicting only you will be deleted or their further publication discontinued without undue delay following withdrawal of consent. References to you in press releases or advertising texts will be removed or anonymised to the extent legally, technically and organisationally possible.

Where you are not in the foreground and the photograph or recording depicts a group of persons, processing and publication may be carried out on the basis of the controller’s legitimate interest (promotion and employer branding), pursuant to Article 6(1)(f) of the GDPR. You have the right to object to such processing at any time in accordance with Article 21(1) of the GDPR by sending an e-mail to rodo@sew-eurodrive.pl. If the objection is upheld, we will take steps to anonymise your image or voice in texts and/or photographs or recordings by pixelation (image, photo, video), distortion (voice, audio) and/or removal of text, insofar as this is legally, technically and economically feasible.

Please note, however, that it cannot be excluded that press releases, advertising texts or photographs or recordings published online with your consent or on the basis of our legitimate interest may continue to circulate online even after they have been deleted or anonymised by us or by media or platforms for which SEW-EURODRIVE is responsible, or that they may have been downloaded, copied or further processed by third parties in their original, non-anonymised form.

IX. Data Protection Information for the Use of Microsoft Teams as a Collaboration Platform

We use Microsoft Teams (hereinafter “MS Teams”), which enables collaboration and communication in virtual teams and channels, including chat-based messaging, presence information, file sharing and storage, as well as online meetings and conferences. Subject to the participants’ decisions and the meeting configuration, image and audio recording may also take place on a voluntary basis, e.g. for documentation, educational or training purposes.

As part of our use of MS Teams, we may process, in particular, the following information: last name, first name, username, user ID / meeting ID, (business) e-mail address, where necessary a (business) telephone number, the date and content of chat messages and video calls, documents sent and shared via the platform, the participant’s image (including face and silhouette visible in the video image), provided that the video camera has been switched on and access has been enabled, a profile picture if used, spoken contributions (content of speech and voice), provided that microphone access has been enabled and/or the participant spoke during the meeting, as well as a recording of the meeting (image and sound), exclusively where participants have been informed in advance, recording has been activated and their consent has been given.

When using MS Teams, we may also process pseudonymised diagnostic data (metadata), i.e. information required for the operation of MS Teams and for product improvement, such as information on the current MS Teams version, operating system version or system crashes. This data are linked to a pseudonymised identifier which Microsoft does not use to identify users. For example, it is used to determine whether a system error occurred for one user or for multiple users. SEW-EURODRIVE does not use such data to assess individuals, monitor their activity or make decisions concerning them.

Detailed information on the scope and purposes of data processing by Microsoft in connection with Microsoft Teams is available in the manufacturer’s documentation at: Microsoft Teams – Privacy - Microsoft Teams | Microsoft Docs

Where SEW-EURODRIVE employees or applicants use video conferencing for the purpose of (professional) communication and task performance, processing is carried out on the basis of Article 6(1)(b) of the GDPR. Where the performance of professional duties or a job application requires the transfer of data to third countries, the legal basis is Article 6(1)(b) of the GDPR in conjunction with Article 49(1)(b) of the GDPR.

Where employees of SEW-EURODRIVE, customers, suppliers, prospective customers, other third parties or employees of companies belonging to the international SEW-EURODRIVE Group participate, for example, in a video conference, personal data are processed for the purpose of performing professional duties and ensuring effective communication within business relationships. The legal basis is Article 6(1)(b) of the GDPR insofar as processing is necessary for the performance of a contract or pre-contractual measures, and otherwise Article 6(1)(f) of the GDPR, i.e. the legitimate interest in ensuring ongoing business communication and cooperation (see section III.1). In exceptional cases involving transfers to third countries, processing is based on Article 6(1)(b) of the GDPR, with the transfer taking place pursuant to Article 49(1)(b) of the GDPR.

If a video conference needs to be recorded, for example to enable persons who could not attend live to view it later or for educational and training purposes, SEW-EURODRIVE will obtain the users’/participants’ consent in a clear, voluntary and verifiable manner, in particular by recording verbal consent at the beginning of the recording or by another unequivocal method. Failure to give consent results in the participant not being recorded. The legal basis is Article 6(1)(a) of the GDPR. In the event of incidental transfers to third countries where no other safeguards apply, such transfers may exceptionally take place on the basis of Article 49(1)(a) of the GDPR.

Access to this information is granted to persons participating in the video conference and/or to whom the recording has been made available, as well as, where applicable, employees of SEW-EURODRIVE and, to the extent necessary for the provision and technical support of MS Teams, authorised employees of Microsoft Ireland Operations Limited and Microsoft Corporation, acting as data processors.

MS Teams is a cloud-based solution. We have entered into a data processing agreement with Microsoft. Microsoft's data centres used for the provision of MS Teams are generally located within the European Union (including, inter alia, Amsterdam, the Netherlands). As the above-mentioned pseudonymised diagnostic data (metadata) may be transferred on a limited basis to Microsoft Corporation in the United States solely for the operation, security and development of MS Teams, Microsoft has implemented additional technical and organisational safeguards for data transfers to and from the USA. Microsoft declares that access by public authorities is generally not granted unless required under applicable law.

SEW-EURODRIVE does not delete content and documents from chats or posts published in teams and channels, provided that their continued storage complies with applicable legal requirements and internal data retention rules. Users may also delete their own content and documents in chats, channels and teams.

If an MS Teams account is deleted, the associated login data as well as the account’s content and documents (stored documents, e-mail inbox) will be permanently deleted after 60-90 days in accordance with Microsoft’s standard retention and deletion procedures, unless further processing beyond this period is required due to statutory retention obligations. Please note that even after deletion of an individual account, content and documents in chats, as well as contributions in MS Teams rooms and channels, will remain accessible to existing users with whom the departing user communicated via the platform.

Where users have consented to the creation and storage of a recording, the recorded data will be deleted immediately upon withdrawal of consent, unless SEW-EURODRIVE is legally obliged to continue processing or the rights of third parties prevent deletion of the entire recording (e.g. the rights of other participants).

Further information on data processing by Microsoft in connection with MS Teams is available at: Microsoft Teams – Privacy - Microsoft Teams | Microsoft Docs

X. Video Surveillance Data Protection Information Notice

In order to protect visitors, employees and assets against threats to life, health, bodily integrity, property and ownership caused by unauthorised third parties, we monitor the premises of our facilities as well as selected business and operational areas by means of video cameras with recording functionality. In this context, the following information may be processed:

• the image of persons captured in the form of video recordings, including their external appearance and behaviour within the monitored area;
• the manner of movement and behaviour of persons within the monitored area.

The cameras do not record sound.

Access to the recordings is granted to employees of the Facility Infrastructure Maintenance Department, IT and the Management Board, exclusively to the extent necessary for the performance of their official duties. Recordings are stored for a period not exceeding 90 days, unless they constitute evidence in proceedings or are required to achieve the purpose for which they were recorded.

The video surveillance system records vehicle licence plate numbers of vehicles entering and leaving the company premises. To the extent that licence plate numbers may lead to the identification of a natural person, they are treated as personal data and processed in accordance with the GDPR. Vehicle data are stored for a period of 3 months. In the event of a suspected serious breach of duties (arising from labour law or civil law), a misdemeanour or a criminal offence, access to the recordings may also be granted to competent managers, authorised employees of the legal and HR departments, members of the works council or the data protection officer, for the purpose of assessment. Where there is a justified suspicion that a criminal offence has been committed, the recordings may be disclosed to the competent investigative authorities. In such cases, storage and processing of the recordings for a period exceeding 90 days is justified, i.e. until the matter has been clarified and finally concluded.

The legal basis for the processing is Article 6(1)(f) of the GDPR. The protection of persons and property (prevention of incidents and prosecution) constitutes our legitimate interest.

With regard to employees of SEW-EURODRIVE, the processing of personal as part of video surveillance is additionally based on Article 222 of the Polish Labour Code in conjunction with Article 6(1)(f) of the GDPR.

Video surveillance is not used for automated decision-making or profiling as defined in Article 22 of the GDPR.

XI. Your rights as the data subject

Every data subject has the following rights:

• Right of access (Article 13,14 and 15 of the GDPR)
• Right to rectification of incorrect data (Article 16 of the GDPR)
• Right to erasure (Article 17 of the GDPR)
• Right to restriction of processing of personal data (Article 18 of the GDPR)
• Right to data portability (Article 20 of the GDPR)
• Right to lodge a complaint with a supervisory authority (Article 77 of the GDPR).

You can object to the processing of personal data for the purposes of direct marketing, including profiling to the extent that it is related to such marketing, at any time without providing a reason.

In addition, any data subject has a general right to object (cf. Article 21, section 1 of the GDPR) to processing for purposes based on the controller's legitimate interest, including profiling carried out on the basis of this provision. In this case, you may indicate reasons relating to your particular situation which justify the objection to the processing of the data. Revoking your consent does not affect the legality of the data processing that occurred with your consent until the time of revocation.

The supervisory authority is the President of the Personal Data Protection Office.

Update: 1/2026